Heart of Ohio Family Health Centers

Information on the federal program - Assistance Listing Number 93.224, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS07897 for project period February 1, 2024 through January 31, 2027 Criteria or specific requirement – Health Centers must comply with federal reporting requirements. Condition – Certain key line items reported on the Uniform Data System (UDS) report were not supportable by underlying data. Within Table 5, Line 8, Columns b and b2, Table 5, Line 10a, Columns b and b2, Table 8A, Line 17, Column c, Table 8A, Line 1, Column c, and Table 8A, Line 2, Column c, there were discrepancies between the reported amounts and the underlying data provided. Cause – Changes were made to amounts initially reported on the UDS report, but the underlying schedules that reflected the final amounts reported were not maintained. Effect or potential effect – Inaccurate filing of reports may result in the federal program not being properly monitored, thus resulting in potential noncompliance with program requirements. Questioned costs – Not applicable. Context – Out of a population of 1 special report required to be submitted during the year under audit, 1 special report was tested. Identification as a repeat finding, if applicable – Is a repeat finding (2024-002) Recommendation – We recommend management implement an additional level of review by someone with knowledge of the reporting requirements. Views of responsible officials and planned corrective actions – Management acknowledges the importance of accurate reporting and proper documentation to meet grant compliance standards. To address this repeat finding, effective immediately, management will implement a mandatory secondary review process. All federal reports submitted to granting agencies will undergo a formal secondary review prior to submission. The reviewer will be a designated individual with demonstrated expertise in federal reporting requirements. Evidence of review (e.g., sign-off or electronic approval) will be retained for audit purposes.

Information on the federal program - Assistance Listing Number 93.224/93.527, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS07897 for project period February 1, 2020 through January 31, 2024 Criteria or specific requirement – Health Centers must comply with federal reporting requirements Condition – The Organization did not have data to support certain line items reported on the Uniform Data System (UDS) report filed. Within Table 5 of the UDS report, the amounts reported within line 10a columns b and b2 were not supportable by underlying data. Cause – The Organization changed Electronic Medical Record systems resulting in a conversion of data mid-year. This added complexity in consolidating the correct reportable amounts. Effect or potential effect – Inaccurate filing of reports may result in the federal program not being properly monitored, thus resulting in potential noncompliance with program requirements. Questioned costs – Not applicable Context – Out of a population of 1 special report required to be submitted during the year under audit, 1 special report was tested. Identification as a repeat finding, if applicable – Not a repeat finding. Recommendation – We recommend management implement an additional level of review by someone with knowledge of the reporting requirements. Views of responsible officials and planned corrective actions – To ensure compliance with federal reporting standards, the Organization will require a secondary review of all federal reports submitted to granting agencies. The designated secondary reviewer shall be an individual that has strong knowledge of the reporting requirements. Additionally, the Organization will implement policies and procedures surrounding file retention of the underlying data that supports federal reports submitted.

Information on the federal program - Assistance Listing Number 93.224, Health Center Program Cluster from the U.S. Department of Health and Human Services, Federal Award No. 6 H80CS07897 for project period February 1, 2020 through January 31, 2024. Criteria or specific requirement - Health centers must prepare and apply a sliding fee discount schedule that incorporates the provisions of 42 CFR 51c.3032 through 56.303g to ensure that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition - The audit of the major federal program identified errors in the application of sliding fee adjustments. Questioned costs - Not applicable Context - Out of a population of 11,125 sliding fee adjustments, a sample of 25 adjustments were tested. Out of the 25 tested, 3 adjustments were incorrectly calculated based on the Organization’s approved sliding fee scales and the patient’s sliding fee application. A non-statistical sampling methodology was used to select the sample. Effect - The sliding fee adjustments were not appropriately applied. Cause - Manual inputs required to calculate the sliding fee discounts resulted in errors in application of the sliding fee scales. Identification as a repeat finding - Not a repeat finding. Recommendation - We recommend that the Organization implement a review process for sliding fee and other adjustments applied in the billing system, including review for the sliding fee application and relating supporting documents. Additionally, we recommend that a member of management with an understanding of the Organization’s billing and sliding fee policies regularly review a sample of sliding fee adjustments in comparison to the Organization’s sliding fee policy. Views of responsible officials and planned corrective actions - The Organization agrees with the finding. See separate auditee document for planned corrective action.

Finding Number: 2019-002: Significant Deficiency ? Cash Management Program Information: U.S. Department of Health and Human Services Consolidated Health Centers Cluster, CFDA 93.224 and 93.527 Award Number: H80CS07897 Criteria: Code of Federal Regulations (CFR) Title 45, Part 75.302(b) and Part 75.305(b) provide requirements of a non-Federal entity, including the requirement that the Organization: 1) maintain accurate and complete records detailing the application of Federal funding; 2) maintain effective control and accountability for funding; and 3) minimize the time elapsing between the transfer of funds from the U.S Treasury and disbursement by the recipient. Condition: The Organization drew down federal funds for sub-awards prior to expenditure of those funds. Audit adjustments were required to be made to the original financial statements presented for the audit based on amounts drawn but not encumbered at year end. Cause: The Organization does not maintain an adequate system for tracking grant expenditures for sub-awards to ensure that funds are drawn either as reimbursements or in a manner which minimizes time elapsing between receipt of funding from the US Treasury and disbursement of the funds by the Organization. Effect: The Organization was required to post audit adjustments. Recommendation: We recommend that management implement a system of tracking allowable expenditures for the sub-awards received to ensure that drawdowns are completed in accordance with the requirements of Part 75.305(b). Management?s Response: See Corrective Action Plan.

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